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To:Public Comment Office of Special Education Michigan Department of Education P.O. Box 30008 Lansing, MI 48909Dear Michigan Department of Education:The MI Dept. of Ed states that the rule revisions will bring our verbiage in line with the federal law, the Individuals with Disabilities Education Act (“IDEA”). This is another way of misleading parents, teachers and concerned citizens. Eliminating state-imposed rules is not done to bring rules in line with federal law. This is done to bring down costs and reduce the number of children found eligible, while reducing necessary specialized instruction.Say NO to these special education rule revisions!-R 340.1832 - Giving local control to Intermediate School Districts (ISD) and school districts to determine special education staffing annually based upon the number of students will explode special education staff caseloads.-R 340.1751(1)(b) of 1976 PA 451, MCL 380.1751(1)(b) - Removing all transparency from the ISD “alternate special education plan.” MI ISDs have authority to override all special education programs, program sizes, teacher caseloads and student age spans, and create their own. The MI DOE is now proposing to remove all transparency and only require that the ISD keeps a copy of this “alternate plan” on file.-R 340.1751(1)(b) of 1976 PA 451, MCL 380.1751(1)(b) - Requiring paraprofessionals to have only a high school diploma. Ensuring the lowest level of qualifications for staff who provide direct instruction in reading, written expression and mathematics.-R 340.1715 - Narrowing the criteria to determine if a student is eligible under an Autism Spectrum Disorder. This will eliminate students on the ASD spectrum needing specialized instruction and related services-R 340.1701b - Removing the ‘multidisciplinary evaluation team” and new limitations on the education personnel responsible for evaluating students in thirteen areas of eligibility.-R 340.1707 & 1708 - Watering down requirements for Hearing Impairment and Visual Impairment teachers due to the critical shortage. So students will be short-changed.-R 340.1721 - Initial Evaluation - Requiring only a psychiatrist, psychologist and social worker in determining a student’s eligibility for an Emotional Impairment How do you “rule out a learning disability” when no achievement testing or cognitive battery is conducted?-R 340.1721a - Requiring parents to initiate consent for special education prior to convening an Individualized Education Program (IEP) team is incongruent with the Individuals with Disabilities Education Act and devaluing the important role that parents play in determining eligibility and services. -R 340.1702 - A student will only be a student with a disability until the high school credits necessary for a diploma are earned and then a district can unceremoniously exit the student and with no concern for the student’s preparedness for Post-Secondary and employability.-R 340.1721e - Eliminating short term objectives for all students. This removes accountable and measurable progress on annual goals.-R 340.1709 / 1709a / 1716 / 1717 - Allowing physician assistants (bachelor’s degree and do not specialize in pediatric evaluations for disabilities) to be on the evaluation team to determine a Physical Impairment (PI), Other Health Impairment (OHI), Traumatic Brain Injury (TBI) and Deaf-Blind.Contrary to MI DOE’s assertion, these proposed revisions have nothing to do with “improving student outcomes.” Rather, they will allow Michigan, ISDs and LEAs to balance their budgets on the backs of students with disabilities. Eliminating the state-imposed special education rules that govern teacher caseloads, special education programs, program sizes and student age spans will not improve outcomes. The most recent data out of the MI Dept. of Ed, Annual Performance Review (February 2014) documents that only 52-percent of students with IEPs graduated high school with a diploma. Michigan needs to turn every possible child into a productive taxpayer. lGutting our special education rules is not the answer and 188,000 students will have no reason to stay home from school in September 2014. Do we really want to send special education and students with disabilities back to the days of being unwelcome guests in our public schools? The answer is a resounding NO.

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